While all companies increasingly use big data to strengthen their competitive position, user data is the singular critical element for market power in advertising-supported sectors, because the core product sold to advertisers is access to that user data. (For data platforms like Apple and Amazon whose products are sold directly to users, not advertisers, this dynamic is different). Media studies professor, Siva Vaidhyanathan, has noted that we have allowed our “our fancies, fetishes, predilections, and preferences” to be captured by companies like Google and resold to their advertisers.[i]

Search, email, online video, social media—these aren’t products sold to users. They are offered to users for free essentially as bait to encourage them to give up their data and agree to become a product packaged by behavioral and demographic category to advertisers. And that user product is not merely a compilation of user activities in any one service but of the combined activity across all the services provided by that advertising-based platform. The more services the user uses, the more data to be packaged for the advertising clients.

So when thinking about competition in these advertising-driven data markets, the point is not how easy it is for users to switch to an alternative product but whether advertisers can easily substitute an alternative online advertising service for a dominant one like Google. Competition in search is not the relevant market; competition in search advertising should be the focus for regulators and the Federal Trade Commission itself has argued that search advertising is even a distinct market for antitrust analysis compared to online display advertising[ii], as have competition authorities in other countries.[iii] It’s worth emphasizing that the FTC’s ruling in January 2013 was only that Google had no harmful monopoly in search as a market, without any finding or analysis of whether Google’s dominance of search advertising violated antitrust law.